Justia Indiana Supreme Court Opinion Summaries

The appellant was charged with two counts of child molestation involving her two young daughters, following disclosures made by one of them to a teacher. Subsequent investigations included forensic interviews with both children and multiple psychological evaluations of the appellant, which diagnosed her with various mental health disorders, including schizophrenia and stimulant use disorder. At different points, experts disagreed about her competency, but she was eventually found competent to stand trial. The appellant’s counsel filed for permission to assert an insanity defense nearly two years after the statutory deadline and only twelve days before trial, citing late-arriving psychological evaluations and ongoing difficulties communicating with the appellant.The Floyd Circuit Court denied the belated insanity defense motion, finding no good cause for the extensive delay, and subsequently a jury found the appellant guilty on both charges. The court sentenced her to two consecutive forty-year terms, for a total of eighty years. On appeal, the Indiana Court of Appeals, in a divided decision, reversed and remanded, holding that the trial court abused its discretion by denying the belated insanity defense notice. The State then petitioned for transfer to the Indiana Supreme Court, which vacated the Court of Appeals’ decision.The Indiana Supreme Court held that the trial court did not abuse its discretion in denying the belated insanity defense motion, as the appellant failed to show good cause for the lengthy delay after receiving relevant psychological evaluations. The Court further held that the children’s out-of-court statements were properly admitted under the Protected Person Statute, as the trial court’s reliability determination was not an abuse of discretion. Finally, the Court found that the eighty-year sentence was not inappropriate given the nature of the offenses and the appellant’s character, and affirmed the trial court’s judgment. View "Tillett v. State of Indiana" on Justia Law

The case concerns an individual who, after being arrested and brought to jail by police officers, was found to have a small canister of pepper spray in his pocket. The defendant was impaired at the time of his arrest and was passively noncompliant, which led officers to skip some standard search procedures and place him directly in a cell. Several hours later, the defendant discovered the pepper spray in his pocket and alerted officers to its presence but did not immediately relinquish the item. Instead, he attempted to use the pepper spray as leverage for demands such as a phone call and a cell transfer and only surrendered the canister after officers deployed pepper spray into his cell.The State charged the defendant with felony possession of material capable of causing bodily injury by an incarcerated person under Indiana Code section 35-44.1-3-7. At trial in Elkhart Superior Court, a jury found him guilty, and the court imposed a four-year sentence. On appeal, the defendant argued that the evidence was insufficient to prove that he knowingly possessed the pepper spray in jail, since he had not voluntarily brought it into the facility or received a reasonable opportunity to relinquish it. The Indiana Court of Appeals agreed with the defendant, reversed the conviction, and found that he had not received a reasonable opportunity to purge himself of the item.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ opinion. The Indiana Supreme Court held that under Indiana Code section 35-44.1-3-7, an incarcerated person is prohibited from knowingly retaining possession of prohibited material after receiving a reasonable opportunity to relinquish it, regardless of how the item entered the facility. The Court found sufficient evidence that the defendant failed to surrender the pepper spray at the earliest reasonable opportunity and affirmed his conviction. View "Gary v. State" on Justia Law

A manager of two limited liability companies, after significant ownership changes and internal conflict, was removed from his managerial role and asked to sell his shares. When he refused, other company members and the companies themselves sued him, initially over breach of the operating agreements. During litigation, they discovered that in 2017, he had secured a $275,000 loan against company real estate, transferred the proceeds to company accounts, and then paid off personal debts with the money without authorization or proper disclosure to his co-owners.The Elkhart Superior Court held a bench trial and found for the plaintiffs on claims including breach of fiduciary duty, unjust enrichment, and, importantly, under the Indiana Crime Victim’s Relief Act (CVRA) for criminal conversion. The court found that the defendant used company funds to pay personal obligations without authorization, constituting criminal conversion, and awarded treble damages, costs, and attorneys’ fees. On appeal, the Indiana Court of Appeals was divided. The majority concluded that because the funds were commingled, they did not qualify as “special chattel” and thus did not support a conversion claim, but affirmed treble damages under the CVRA on the theory of theft. A concurring judge disagreed with the special-chattel requirement and believed conversion had been established.The Indiana Supreme Court granted transfer, vacating the appellate opinion. The Court held that money need not be “special chattel” or segregated to support a criminal-conversion claim or a CVRA action. The statutory elements of conversion are sufficient, and the judicially created special-chattel requirement is not part of the criminal-conversion statute. The Court affirmed the trial court’s award of treble damages under the CVRA but directed the award to be made to the proper company victim. It also affirmed the findings on breach of fiduciary duty and unjust enrichment. View "Harper v. S&H Leasing LLC" on Justia Law

Yerano Martinez was seriously injured in a car accident after he drove through a stop sign at an intersection. Martinez alleged that an overgrown bush, located on property owned by Jeffrey Smith, obscured the stop sign. The bush extended from Smith's property into the county's right-of-way, which is a strip of land adjacent to the roadway. Martinez argued that Smith failed in his duty to maintain his property so as not to obstruct the stop sign for passing motorists.The Marion Superior Court granted summary judgment to Smith, finding that, under the Indiana Supreme Court’s previous decision in Reece v. Tyson Fresh Meats, Inc., Smith owed no duty to motorists unless a hazardous condition actually extended onto the paved portion of the roadway. The Indiana Court of Appeals unanimously affirmed, interpreting Reece to mean that a landowner’s duty to motorists is limited to conditions that extend onto the roadway itself, not merely into the public right-of-way or county easement.The Indiana Supreme Court reviewed the case on transfer. The Court held that a landowner’s common-law duty under Reece to refrain from creating hazardous conditions for passing motorists on adjacent highways includes traffic-control devices, such as stop signs, located within the public right-of-way. The Court clarified that the duty is not confined to the paved part of the road but extends to conditions that obstruct traffic-control devices within the right-of-way. Because Smith admitted the bush encroached into the public right-of-way and created a visual obstruction, the hazardous condition was not wholly contained on his property. The Supreme Court concluded that the trial court erred in granting summary judgment to Smith and reversed the lower court’s decision. View "Martinez v. Smith" on Justia Law

A man designated his sister as the beneficiary of his employer-issued life insurance policies, amounting to $150,000, with instructions that she distribute the proceeds to his three daughters. The man, suffering from declining health, relied on his sister to manage his finances, legal affairs, and healthcare decisions, creating a fiduciary relationship. After his death, the sister claimed the insurance proceeds for herself, contrary to the instructions. The daughters sought a constructive trust over the proceeds, claiming the sister was to hold the funds in trust for them, while the sister denied any fiduciary breach and asserted entitlement under the policy.The Allen Superior Court, after a bench trial, found no undue influence or fraud in the beneficiary designation but concluded that the sister breached her fiduciary duty by failing to distribute the proceeds as instructed. The court imposed a constructive trust in favor of the daughters, finding by clear and convincing evidence that the deceased intended for them to receive the insurance money. The sister appealed, arguing that the Employee Retirement Income Security Act of 1974 (ERISA) preempted such state-law remedies and that the evidence did not meet the required standard. The Indiana Court of Appeals twice reversed the trial court, holding that ERISA preempted the remedy, but the Indiana Supreme Court remanded for application of the correct standard of proof without reaching the preemption issue.The Indiana Supreme Court, upon further review, held that the sister waived her ERISA preemption argument by not raising it in the trial court. The court affirmed the trial court's imposition of a constructive trust, concluding that the findings of a fiduciary relationship and breach of duty were supported by clear and convincing evidence. Accordingly, the Indiana Supreme Court affirmed the trial court’s judgment in favor of the daughters. View "Geels v. Flottemesch" on Justia Law

A defendant violently attacked and confined a homeowner over a six-hour period in the homeowner’s house. The defendant struck the homeowner multiple times, tied him up with various restraints, and used weapons, including a handgun. During the ordeal, the homeowner was forced to help the defendant carry stolen items, attempted to escape unsuccessfully, and was continuously under threat until he finally managed to flee. As a result, the State charged the defendant with multiple felonies, including two counts of criminal confinement: one as a Level 3 felony (for use of a deadly weapon) and another as a Level 4 felony (for inflicting moderate bodily injury).The Ohio Circuit Court entered convictions for both confinement counts and sentenced the defendant to consecutive terms for those offenses, along with sentences for other crimes. On appeal, the Indiana Court of Appeals affirmed the convictions, applying the Wadle test for double jeopardy, even though the parties had agreed that the Powell test was applicable.The Indiana Supreme Court reviewed the case on transfer. It held that when a statute defines a base offense and elevated forms (such as higher felony levels based on enhancing circumstances), those forms constitute a single statutory offense. Therefore, the Powell test, not the Wadle test, governs whether multiple convictions for elevated offenses violate Indiana’s substantive double jeopardy doctrine. Applying the Powell test, the court found the evidence supported only a single, continuous period of criminal confinement, not two discrete offenses. The court reversed the conviction for the lesser (Level 4) offense, ordered the trial court to vacate that conviction, and remanded for resentencing, thereby reducing the defendant’s aggregate sentence. View "Moyers v. State of Indiana" on Justia Law

Several insurance companies participate in Indiana’s Assigned Risk Plan, a statutory system designed to ensure workers’ compensation coverage for employers unable to obtain insurance in the voluntary market. One participating insurer, Technology Insurance Company, provided coverage under this system. After handling a significant workers’ compensation claim and settling for over $2 million, the company sought reimbursement from the Indiana Compensation Rating Bureau, as provided in their agreements. The Bureau denied reimbursement, alleging the company had acted fraudulently. The company followed the dispute-resolution procedures required by contract, ultimately securing a favorable ruling from an administrative law judge, who ordered full reimbursement. The company then sought additional relief—attorneys’ fees, interest, and expenses—from the agency, but received no response despite repeated requests.After payment of the principal settlement amount but no fees or interest, the company sought judicial review in the Marion Superior Court, which found the Department of Insurance’s failure to rule was arbitrary and contrary to law. The trial court ordered the Bureau to pay fees, interest, and expenses. The Bureau appealed, and the Indiana Court of Appeals reversed, holding the company’s claims for fees were not governed by the parties’ agreements and must be presented anew to the Bureau.The Indiana Supreme Court granted transfer, vacating the appellate court’s decision. The Court held that the company was required to exhaust administrative remedies, as set out in the Assigned Risk Plan and related agreements, but found the company had done so by pursuing its claims through the prescribed channels. The Court further held that the company was entitled to prejudgment interest, attorneys’ fees, and expenses under the contracts, and that these collateral claims could properly be added in the judicial review proceedings without further agency exhaustion. The judgment for the company was affirmed and the case remanded to the trial court for calculation and award of appropriate fees, interest, and expenses. View "Indiana Compensation Rating Bureau v. Technology Insurance Company" on Justia Law

After a divorce, a former husband and wife entered into a settlement agreement incorporated into their dissolution decree, in which the wife was awarded the marital home and agreed to assume responsibility for a specific home-related debt—a loan with Wells Fargo. The agreement also provided that the husband could seek damages for any harm to his credit if payments were not made on time. Several years later, the wife stopped making payments on the loan and filed for bankruptcy, after which the debt to Wells Fargo was ultimately discharged. The husband did not make any loan payments himself and later filed a contempt petition, claiming that the wife’s failure to pay the loan damaged his credit and caused him financial losses, including increased interest on another loan and a lost opportunity to secure a home-construction loan.The Marion Superior Court held a hearing and found the wife in contempt for willfully failing to pay the loan but did not award the husband damages. The court found the alleged damages to be speculative and unproven due to insufficient supporting evidence. The husband appealed, and the Indiana Court of Appeals partially reversed, instructing the trial court to award damages. However, the appellate opinion was not certified, and the trial court nevertheless issued a revised order in line with the appellate mandate.The Indiana Supreme Court reviewed the case. It held that the trial court did not clearly err in declining to award damages, as the husband’s evidence of financial harm was speculative and inadequately supported. The Court further held that the trial court’s revised order was void because it was issued while the appeal was pending and before the appellate opinion was certified. The Indiana Supreme Court affirmed the trial court’s original order and reminded lower courts and parties not to act based on uncertified appellate opinions. View "Norris v. Norris" on Justia Law

Caryl Rosen brought a negligence suit against a hospital after she tripped and fell on a large entryway mat in the hospital’s main lobby. She alleged that the mat’s condition caused her fall and resulting injuries. After the incident, hospital security preserved video footage from one camera that captured Rosen’s fall and provided it to her attorney. There were two other cameras in the area, but the hospital’s security supervisor stated that neither captured the fall. Rosen claimed that video from before the fall, as well as footage from the other cameras, might have shown the mat’s condition and supported her case.Rosen moved for spoliation sanctions in the Lake Superior Court, asserting that the hospital failed in its duty to preserve relevant evidence. The trial court denied her motions, finding that the hospital had not spoliated evidence because the additional footage did not capture the fall. The trial court also excluded mention of unpreserved video at trial and refused Rosen’s proposed jury instruction allowing an adverse inference from the absence of that evidence. The jury returned a verdict for the hospital.On appeal, the Indiana Court of Appeals reversed, holding that the trial court abused its discretion by finding no spoliation and by refusing the adverse inference instruction. The appellate court reasoned that unpreserved footage might have shown the mat’s condition. The Indiana Supreme Court, upon granting transfer and vacating the appellate opinion, held that the trial judge’s decisions were within her discretion. The Court concluded that the hospital’s evidence preservation was reasonable and that the trial court acted within its discretion in excluding the evidence and refusing the adverse inference instruction. The Indiana Supreme Court affirmed the judgment for the hospital. View "Rosen v. Community Healthcare System" on Justia Law

A patient was hospitalized after contracting COVID-19 and, as his condition worsened, was transferred between several hospitals in Kentucky and Indiana. During his treatment, he was intubated, placed on a ventilator, and medically immobilized. While under this care, he developed a severe bed sore that progressed to necrotizing fasciitis. Despite ongoing treatment, he ultimately died, with his death certificate listing multiple causes including cardiopulmonary arrest and sepsis. His estate claimed that negligence in the treatment of the bed sore caused his death and filed a proposed medical malpractice complaint against more than eighty healthcare providers.The case began when the estate filed its complaint with the Indiana Department of Insurance, while a medical-review panel was being requested. Before the panel was constituted, the providers moved for summary judgment in Vanderburgh Superior Court, arguing they were immune from liability under Indiana’s Healthcare Immunity Act, Premises Immunity Act, and the federal PREP Act. The trial court granted summary judgment for the providers, finding that statutory immunity applied and that the court, not the medical-review panel, could decide the immunity issue. The estate appealed, and the Indiana Court of Appeals reversed, holding that the question of immunity required expert input from the medical-review panel, especially regarding causation.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. It held that the trial court could make a preliminary determination on statutory immunity without waiting for a medical-review panel’s opinion, since the facts relating to the connection between the patient’s COVID-19 treatment and his injury were undisputed for summary judgment purposes. The court further held that the providers were immune from civil liability under both state and federal law, as the patient’s injuries arose from treatment provided in response to the COVID-19 emergency. The court affirmed summary judgment for the providers. View "Estate of Waggoner v. Anonymous Health System, Inc." on Justia Law